Provisional draft: This page contains visible placeholders and must be reviewed before it becomes a final legal policy.

Privacy Policy

This Germany-oriented draft explains the website services currently planned and identifies details that the legal operator must confirm.

Important: This is a provisional draft, not a statement that every listed legal detail has been confirmed. Before publication as a final policy, replace every highlighted placeholder and verify the data practices of each released game.

1. Controller and contact details

ArcticExile is operated by [INSERT LEGAL OPERATOR OR COMPANY NAME], located at [INSERT BUSINESS ADDRESS AND COUNTRY]. In this policy, “ArcticExile,” “we,” “us,” and “our” refer to that operator and data controller. The complete provider details must also be added to the Legal Notice.

For privacy questions or requests, contact support@arcticexile.com.

2. Scope and legal framework

This policy applies to the ArcticExile website at arcticexile.com. It is also intended as a starting point for future ArcticExile mobile games, but each game’s actual data collection, permissions, third-party services, age rating, and regional requirements must be confirmed before release. This draft is structured for the EU General Data Protection Regulation (GDPR), the German Federal Data Protection Act (BDSG), and the German Telecommunications Digital Services Data Protection Act (TDDDG). The operator must confirm the laws and supervisory authority that apply after its location and activities are finalized.

3. Information collected through this website

Information you choose to send

If you email us, we may receive your name, email address, message, and any other information you choose to include. Please do not send passwords, full payment-card details, or unnecessary sensitive information.

Technical information

The website is hosted on Cloudflare Pages. Cloudflare may process technical request information needed to deliver and protect the website, such as IP addresses, device and browser information, requested URLs, timestamps, and security signals. Cloudflare acts under its own terms and privacy documentation.

Email communication

This website does not collect or transmit contact-form submissions. Selecting an email link opens your email application. Messages are then processed by your email provider and the email providers used by ArcticExile. General inquiries can be sent to contact@arcticexile.com.

Shelter Ascendant browser game

The browser alpha at /shelter/ stores your survivor name, appearance, game progress, equipment and settings in this browser's local storage facilities, including IndexedDB. It keeps recovery copies locally. Optional login and cloud saves are available. While signed in, cloud saves connect automatically and upload account progress to ArcticExile's VPS over HTTPS. An empty account starts from your guest survivor, preserving the guest copy separately. This includes survivor identity, equipment, progress, settings, expedition checkpoints, pending results and reward timestamps. The database keeps the current and previous cloud copy, revisions and save timestamps; restricted database backups also contain saves. Guest progress remains local. Hosting requests are still processed as described above. Clearing this website's browser data removes local game storage; the game's reset option keeps a local recovery copy instead of erasing all stored copies. A local reset does not erase the cloud copy. To transfer progress, sign in on the other device; cloud progress resumes automatically. Conflicting cloud and device changes require a choice. The browser stores a per-account sync revision and save fingerprint to detect these conflicts. Clearing browser storage deletes unsynced local changes.

If you choose to register, the account service at api.arcticexile.com stores a chosen username, a server-generated account ID, password and recovery-code hashes, account status, and creation/update timestamps in PostgreSQL on ArcticExile's VPS. No email address or real name is required. Passwords and recovery codes are sent over HTTPS; plaintext passwords and recovery codes are not stored in the database or request logs. Keep the recovery code privately: it can be used to reset your password.

Login sets the necessary Secure, HttpOnly, SameSite cookie __Host-shelter_session on the API hostname, with a maximum lifetime of seven days. The server stores a hash of the session token with its expiry time. Logout revokes that session; password recovery revokes all sessions for the recovered account. Short-lived hashed IP/username rate-limit counters help prevent abuse and are cleaned up after expiry. Accounts persist until removed by the operator; contact support@arcticexile.com for account-data or deletion requests. Restricted backups may retain earlier records. The broader policy's operator details and retention schedule still require operator review.

Private studio administrator login

The owner-only statistics dashboard uses a separate administrator username and password, not a Shelter Ascendant player account. The administrator is created through a private local setup connected to the operator's server; there is no public registration. The server stores the chosen administrator username, a salted password hash, account status and creation/update timestamps. Plaintext passwords are not stored or logged.

Administrator sign-in sets the necessary Secure, HttpOnly, SameSite=Strict cookie __Host-arctic_studio_session on the API hostname for up to 12 hours. The server stores a hash of the token and its expiry; sign-out revokes only that studio session and does not sign the administrator out of the game. Short-lived keyed IP/username sign-in counters expire after 15 minutes and are cleaned up every five minutes, as are expired studio sessions. Administrator credentials persist until the operator removes or replaces them through trusted server administration. Restricted backups can retain earlier records. Signing into the dashboard does not enable optional player-statistics collection.

Optional Shelter play statistics

Not yet enabled: Collection is currently disabled. The following describes the prepared feature; it does not mean that play activity is already being recorded.

Shelter Ascendant is prepared to offer an optional first-party play-statistics choice, separate from login and cloud saves. Choosing “No thanks” does not affect gameplay. Choose “Allow (16+)” only if you are at least 16 years old. The legal operator must review the game's age audience and consent process before treating this provisional policy as final.

With permission, the browser sends a random per-play token, the game identifier, the consent-text version, and start, activity, pause and end signals to api.arcticexile.com. Collection starts only after the game is ready and you interact with it. Signals are sent approximately every 30 seconds while visible and recently used; three minutes without game input stops reporting. The server uses its own timestamps to calculate session counts, approximate active play time and a rolling 90-second active-session count. A network failure can leave a session visible until that window expires.

For signed-in players, the service uses the existing necessary login cookie to derive a keyed account pseudonym, allowing one account to be counted once across tabs and devices. The statistics tables do not store usernames, email addresses, passwords, save contents, device fingerprints or raw IP addresses. IP addresses necessarily reach the hosting infrastructure; this statistics service uses only short-lived in-memory keyed IP digests for abuse limits. Guest sessions cannot be counted as unique people. Only the studio owner can read the private aggregated dashboard.

Pseudonymous session and daily membership records are retained for 90 days; aggregate daily totals for 730 days. The choice is remembered in local storage for up to 180 days without a persistent visitor ID. Reopen “Play statistics settings” in the game and choose “No thanks” to withdraw at any time. This stops new activity reporting and sends one final session-close signal; it does not retroactively erase previously collected records. Contact support for data-rights requests; a signed-in account may be needed to locate an account pseudonym. A random guest session may no longer be attributable after the tab closes. Restricted database backups can retain older records under the operator's still-to-be-confirmed backup schedule.

The stated basis for this optional measurement is consent under Article 6(1)(a) GDPR and, where applicable, § 25(1) TDDDG. Withdrawal does not affect processing already based on consent. The final controller details, hosting processor arrangements, backup retention and age-related requirements still require operator/legal review. No historic activity from before collection began is reconstructed.

4. Mobile game data

TinyMerge has been identified as a Google Play game in closed testing, but its game-specific data practices have not been confirmed in this draft. Before testing expands or the game launches publicly, complete the following:

  • [LIST DATA COLLECTED BY EACH GAME, OR CONFIRM THAT NONE IS COLLECTED]
  • [LIST ANDROID PERMISSIONS AND WHY THEY ARE NEEDED]
  • [LIST ADVERTISING, ANALYTICS, CRASH REPORTING, CLOUD SAVE, ACCOUNT, OR OTHER SDK PROVIDERS]
  • [CONFIRM CHILDREN’S PRIVACY AND AGE-AUDIENCE APPROACH]
  • [CONFIRM GOOGLE PLAY DATA SAFETY DISCLOSURES]

5. How information is used

Website inquiry information may be used to respond to messages, provide support, investigate bugs or security concerns, maintain business records, prevent abuse, and comply with applicable legal obligations. Add or revise purposes when game data practices are confirmed.

6. Purposes and legal bases

Under Article 6(1) GDPR, processing may be based on:

  • Article 6(1)(b), when processing is necessary to respond before a contract or perform a contract;
  • Article 6(1)(c), when processing is necessary to comply with a legal obligation;
  • Article 6(1)(f), for legitimate interests in answering inquiries, securing the website, preventing abuse, and maintaining reliable operations, where those interests are not overridden by individual rights; or
  • Article 6(1)(a), consent, where consent is specifically requested.

The operator must confirm the purpose, legal basis, and any legitimate-interest assessment for each actual processing activity: [CONFIRM THE FINAL PURPOSE-AND-LEGAL-BASIS TABLE].

7. Sharing and service providers

Website information may be processed by service providers that help operate the website and communication channels, including Cloudflare for hosting and security and email providers used by ArcticExile. We do not state that information is sold. Confirm any future advertising or data-sharing activity before a game release: [CONFIRM WHETHER PERSONAL INFORMATION IS SOLD, SHARED FOR TARGETED ADVERTISING, OR OTHERWISE DISCLOSED].

8. International transfers

Cloud service providers may process information in countries other than your own. The legal operator must confirm locations and transfer safeguards where applicable: [CONFIRM INTERNATIONAL TRANSFER MECHANISMS].

9. Retention

Email records should be kept only as long as reasonably needed for the inquiry, support, security, accounting, or legal purposes. Insert an approved schedule: [INSERT RETENTION PERIODS OR CRITERIA].

10. Device storage, cookies, and analytics

The public marketing pages do not add audience-measurement scripts, advertising trackers or social-media widgets. Shelter's optional play-statistics controls and preference storage are described above. Necessary game storage, account cookies and cloud-save synchronization are separate. Cloudflare may use strictly necessary mechanisms for security and reliable delivery. Under § 25 TDDDG, optional storage of or access to information on a visitor’s device generally requires informed consent unless a statutory exception applies.

11. Your rights

Depending on where you live, you may have rights to request access, correction, deletion, restriction, objection, portability, or withdrawal of consent. You may also lodge a complaint with a data protection supervisory authority. These rights can be limited by law. Send requests to support@arcticexile.com. The operator must identify the competent German authority after its business location is confirmed: [INSERT COMPETENT GERMAN DATA PROTECTION SUPERVISORY AUTHORITY].

12. Children’s privacy

The intended audience and child-directed status of TinyMerge and future games have not been confirmed. Before release, document the age audience, parental-consent approach, and any child-specific protections: [CONFIRM AGE AUDIENCE AND CHILDREN’S DATA PRACTICES].

13. Security

We use reasonable technical and organizational measures appropriate to the website, but no internet transmission or storage method can be guaranteed completely secure. The operator should document internal access, deletion, incident-response, and vendor-review processes.

14. Changes to this policy

When this policy is finalized or updated, the effective date above will be changed. Material changes may be communicated through the website or a game where appropriate.

15. Contact

Privacy contact: support@arcticexile.com

Legal operator: [INSERT LEGAL NAME]
Address: [INSERT POSTAL ADDRESS]
Representative or data protection contact, if required: [INSERT DETAILS OR “NOT APPLICABLE”]

Provider information is also listed in the Legal Notice.